The OECD Committee on Fiscal Affairs has been working to update and modernise the existing provisions in Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG) which provides guidance on intra-group services.
This work aims to ensure alignment between the guidance on intra-group services and the foundational principles in Chapters I, II and III of the OECD TPG. The proposed revisions also seek to further enhance clarity and provide practical illustrations through the inclusion of new examples. The revisions are not intended to change the general principles underlying the transfer pricing analysis of intra-group services.
The OECD recognises the value of receiving input at this stage from a wide range of stakeholders, to consider the ways that the issue presents itself to different groups, industries or across different regions. To this end, a document containing proposed revisions to Chapter VII of the OECD TPG is released for public consultation:
